California Significant New Alternatives Policy (SNAP)
The California Global Warming Solutions Act of 2006 (AB 32) creates a comprehensive, multi-year program to reduce greenhouse gas (GHG) emissions in California. California Senate Bill (SB) 32 of 2016 requires a 40 percent reduction in GHG emissions below 1990 levels by 2030. Taking action on short-lived climate pollutant (SLCP) is an important part of achieving California's climate goals. SB 1383 requires a 40 percent reduction of hydrofluorocarbon (HFC) emissions below 2013 levels by 2030.
HFCs are synthetic gases that are used in a variety of applications including refrigeration, air-conditioning, foam blowing, solvents, aerosols, and fire suppression. HFCs are SLCPs, which are powerful GHGs that remain in the atmosphere for a much shorter period of time than longer-lived climate pollutants, such as CO2, but are more potent when measured in terms of global warming potential (GWP) which can be hundreds, to thousands of times greater than CO2.
CARB was relying on United States Environmental Protection Agency (U.S. EPA) Significant New Alternatives Policy (SNAP) Rules to meet a large portion of HFC emission reductions required by SB 1383. However, On August 8, 2017, in Mexichem Fluor. v. U.S. EPA, the D.C. District Circuit Court significantly limited the U.S. EPA ability to regulate high-GWP HFCs under the federal SNAP Program Rules.
In 2018, California took action and backstopped key federal SNAP prohibitions by adopting a new CARB HFC regulation and through new legislation, the California Cooling Act (SB 1013). Both the CARB HFC Regulation and SB 1013 took effect January 1, 2019. The regulation and the Senate Bill are referred to together as California SNAP, and cover all the end-use specific HFC prohibitions covered by U.S. EPA SNAP Rules 20 and 21, with the exception of Mobile Vehicle Air Conditioning (MVAC).
In 2020, CARB amended the 2018 HFC regulation to adopt GWP limits for new refrigeration and air conditioning equipment, which ensures that industry not only shifts away from the highest GWP refrigerants, but swiftly transitions to technologies with the lowest GWP that are technologically and commercially feasible. The amendments also require retail food companies owning existing systems containing more than 50 pounds of refrigerant in retail food facilities to achieve company-wide HFC reductions – either through a reduction in their company-wide weighted-average GWP or in the alternative, reduce their Greenhouse Gas Emission Potential.
The amendments also establish the “Refrigerant Recovery, Reclaim, and Reuse Requirements,” or R4 Program. The R4 Program requires AC and VRF manufacturers to use a specified minimum amount of reclaimed refrigerant in new equipment or in the servicing of existing equipment. All of the amendments can found in the regulation text. The regulation does not cover HFC uses in, and emissions from, motor vehicle air conditioning (MVAC) systems. Please see CARB’s Clean Cars Standards and Low-Emission Vehicle (LEV) III regulation for more information on MVAC regulations.